The Fifth Circuit has declined to retroactively apply the Board of Immigration Appeals’ decision in Matter of Diaz Lizarraga - which altered the definition of a crime involving moral turpitude as it applies to theft offenses - finding that doing so would impact the expectations of criminal defendants who accepted pleas to theft offenses in reliance on the prior rule.
The full text of Monteon-Camargo v. Barr can be found here:
http://www.ca5.uscourts.gov/opinions/pub/17/17-60345-CV0.pdf